What human rights and modern slavery work actually involves

Human rights due diligence (HRDD) is the process by which companies identify, prevent, mitigate, and account for actual and potential adverse impacts on people across their operations and value chains. Modern slavery, encompassing forced labour, child labour, debt bondage, and human trafficking, is among the most severe human rights risks in global supply chains. For corporate teams, this work involves supply chain risk mapping, supplier assessments, grievance mechanism design, remediation management, and disclosure under the UK Modern Slavery Act, the EU CSDDD, and CSRD's S2 (Workers in the Value Chain) standard.

Why it's harder in practice than it looks

Risk is concentrated where visibility is lowest

Modern slavery and severe labour abuses are most prevalent in raw material extraction, agricultural harvesting, and processing, typically at tier 2 or deeper in the supply chain, far from the purchasing decisions of corporate procurement teams. Building visibility into these tiers requires sustained engagement with direct suppliers and specialist mapping tools that go beyond standard supplier questionnaires.

Audits consistently fail to detect forced labour

Research across multiple industries, including electronics, garments, and fresh produce, shows that third-party social audits regularly fail to identify cases of forced labour that are later discovered through other means. Workers are coached before visits, auditors spend limited time on site, and the dynamics of an employer-facilitated audit systematically suppress disclosure. Due diligence frameworks that rely primarily on audit certificates have a false sense of assurance.

Legislation is moving faster than corporate programmes

The EU CSDDD (effective from 2027 for the largest companies), Germany's LkSG (effective 2023), and France's Duty of Vigilance Law require active due diligence and remediation, not just reporting on what has been done. Companies that have treated modern slavery compliance as an annual reporting exercise are significantly behind where legislation now requires them to be.

Grievance mechanisms are formally present but functionally absent in most supply chains

The UN Guiding Principles require companies to provide accessible grievance mechanisms for workers in their supply chains. Most companies reference grievance hotlines in their supplier codes; few have mechanisms that are genuinely accessible, safe, and trusted by workers in high-risk sourcing regions. Worker voice requires investment in design, promotion, and follow-through.

What good looks like

A credible human rights and modern slavery programme includes a supply chain risk mapping exercise that identifies high-risk tiers, geographies, and commodities; worker-centred due diligence approaches that supplement audits with worker interviews, wage data analysis, and local civil society engagement; an accessible grievance mechanism promoted directly to workers rather than only to supplier management; a time-bound remediation process for identified issues; and disclosure that goes beyond template compliance to provide specific, evidence-based information about the due diligence conducted and outcomes achieved.

When to bring in external support

Modern slavery and human rights due diligence require specialist knowledge of at-risk sectors, geographies, and due diligence methodologies that goes well beyond standard procurement capability. Leafr's network includes human rights due diligence specialists who have designed and implemented HRDD programmes for fashion, food, manufacturing, and professional services clients, providing both technical expertise and on-the-ground supply chain knowledge.

Frequently asked questions

What is the UK Modern Slavery Act and what does it require?

The Modern Slavery Act 2015 requires commercial organisations with an annual turnover of £36m or more that supply goods or services in the UK to publish an annual transparency statement approved by the board. The statement must describe steps taken to ensure modern slavery is not present in the business or supply chain. Government guidance identifies six areas of best practice: organisational structure and supply chains, policies, due diligence, risk assessment and management, KPIs, and training. Quality of disclosure varies enormously; the government's modern slavery statement registry allows public comparison.

What is the EU CSDDD and how does it differ from modern slavery reporting?

The EU Corporate Sustainability Due Diligence Directive requires large EU companies and certain non-EU companies with significant EU turnover to conduct ongoing human rights and environmental due diligence across their value chains, implement processes to address identified adverse impacts, and report on their approach. Unlike the Modern Slavery Act, which focuses on transparency, CSDDD requires active due diligence and imposes civil liability for failing to prevent or address identified harms. It represents a fundamentally different compliance standard.

What is human rights due diligence?

Human rights due diligence (HRDD) is the process defined by the UN Guiding Principles on Business and Human Rights through which companies identify, prevent, mitigate, and account for adverse human rights impacts connected to their operations and value chains. It is an ongoing process, not a one-time assessment, that includes risk identification, action to address risks, tracking effectiveness, and transparent communication. HRDD is the foundation of both the CSDDD and voluntary frameworks such as the OECD Guidelines for Multinational Enterprises.

What is forced labour and how does it differ from modern slavery?

Forced labour is defined by the ILO as work performed under threat of penalty and for which the worker has not offered voluntarily. It includes situations of debt bondage, retention of identity documents, restricted freedom of movement, and threats of violence. Modern slavery is a broader term encompassing forced labour, child labour, human trafficking, forced marriage, and domestic servitude. Both terms are used in corporate due diligence frameworks, though the ILO forced labour indicators provide the most operational definition for supply chain risk assessment.

How should companies respond when modern slavery is identified in their supply chain?

The immediate priority is worker protection, ensuring workers are not further harmed as a result of the discovery. This may involve securing back wages, facilitating access to support services, or in severe cases supporting worker exit from the situation. Long-term response should focus on supplier remediation, working with the supplier to address root causes, rather than immediate delisting, which may remove the leverage needed to improve worker outcomes. Remediation should be time-bound with defined milestones and independent verification of progress.